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In 2004 the SSK submitted to ICRP its comments on the “Draft for Consultation” [1] of the 2005 Recommendations of the ICRP. Regarding the topic “Protection of the Environment” the SSK made the following statements:

- In Publication 60 the ICRP expressed the belief that the standards of environmental control needed to protect man will ensure that other species are not put at risk. In paragraph (242) of the draft recommendation the ICRP declares that “the Commission still believes that this judgement is correct in general terms”.

- No scientific reasons are presented by the ICRP to support this statement. Current results of research projects, e.g. FASSET, are not evaluated and conclusions from this research are not drawn. Instead, a common approach for the radiological protection of humans and non-human organisms is recommended without giving reasons for any need of such a system.

- In Annex B.3 the ICRP recommends to develop a small set of reference animals and plants plus their relevant databases to calculate doses according to the procedure to protect man. According to this recommendation a lot of (limited) resources would be exhausted to model doses of reference animals and plants. Therefore, this strategy should only be embarked if there is a need to do so, but the draft recommendations of the ICRP do not give any scientific basis for this approach on the one hand. On the other hand, the protection of soil, air and water is not recommended by the ICRP. In other fields of environmental protection these non-living parts of the environment must also be protected and sustainability is an important aspect of protection. Therefore, ICRP should indicate how this aspect should be considered, e.g. by limiting releases of Kr-85 and of long-living radionuclides (C-14, Cl-36, Mn-53, Tc-99, I-129, Cs-135, transuranium nuclides etc.) to the environment according to the stand of the art and independent from potential doses to man or non-human beings.

The present ICRP Draft for discussion “The Concept and Use of Reference Animals and Plants for the Purposes of Environmental Protection” [2] is intended to be a foundation document for the future basic ICRP recommendations with respect to environmental protection. It was hoped by the SSK that it would clarify and resolve some of the above mentioned concerns. However, this is not the case.

Therefore, the SSK confirms its abovementioned earlier statements, The SSK states to major points of critics for the new draft [2]:

1. The policy chosen by ICRP to provide guidance for the protection of the environment is not adequate and does not satisfy the needs of regulatory approaches in environmental protection.

The proposed concept and use of Reference Animals and Plants will inadequately enlarge the regulatory and surveillance efforts and will waste human and monetary resources without improving radiation protection and the protection of the environment. Given the large number of open scientific and technical questions described in the present document [2], it will take many years for the concept to become feasible. It is not mature to provide a basis for an actual ICRP recommendation.

To provide a practicable basis for environmental protection one needs:
- A demonstration that the ICRP 60 statement (“The Commission believes that the standards of environmental control needed to protect man to the degree currently thought desirable will ensure that other species are not put at risk”) [3] is correct for those parts of the environment where humans are present and protected according to actual radiation protection standards.
It is urgently needed since the ICRP 60 statement is used in many countries for regulatory purposes. Several countries recognize the need to develop guidance and criteria to explicitly demonstrate that the environment is protected [4]. It can be done on the basis of existing scientific knowledge (e.g. the FASSET [5], EPIC [6] results and older evaluations [7, 8].
- A concept and criteria are needed for the protection of the abiotic environment, i.e. air, soil and water.

From the regulatory point of view this is urgent since it is state of the art for non radioactive pollutants.

ICRP should only embark on an approach based on Reference Animals if the necessity has been proven, i.e. by identifying environmental compartments or situations in which the ICRP 60 belief is demonstrated to be wrong. This approach should then be limited to such situations.

2. Even if one accepts the approach of reference Animals and Plants, the document [2] does not fulfil the requirements to be met by a foundation document.

A foundation document should provide a sound basis for a recommendation by ICRP. The present document [2] describes only some aspects of the proposed Concept and Use of Reference Animals and Plants. It does not provide evidence or guidance how the complete concept could be applied in case ICRP makes a respective recommendation. The document does not present new scientific evidence. It contains many statements about intentions and future needs. But it is not final. It is incomplete, rising more open questions than giving answers. It does not provide a sufficient basis for an ICRP recommendation in the important field of environmental protection. In its present form the document [2] is unnecessary and useless.